Continental Airlines

The FAA intends to issue Airworthiness Directive which, in part, will require operators to replace the firing cable found in the 5A3294 and 5A3295 series 767 door slides per Boeing service bulletin 767-25A0395. This Boeing service bulletin, in turn, instructs for the accomplishment of Goodrich service bulletin 5A3294/5A3295-25A362. Continental Airlines has no objection to paragraph (b) of the NPRM and the associated service bulletins. Continental has completed the Goodrich service bulletin on approximately 70% of their 767 main door slides. We don’t anticipate any problem in meeting either a 36 or 72 month compliance period from the effective date of a forthcoming AD. Continental’s only concern with this NPRM is the apparent overlap of paragraph (b)’s requirement with that of proposed rulemaking 2007-NM-323-AD. This previously issued NPRM also requires operators to comply with the same Boeing and Goodrich service bulletins but at a different compliance time interval (3 years). This will undoubtedly cause confusion with operators and suppliers for the 767 slide packs in question. Continental requests the FAA to remove paragraph b) from NPRM 2001-NM-237- AD and let the firing cable replacement requirement exist only with NPRM 2007- NM-323-AD’s pending AD.